{"id":933152,"date":"2026-05-21T00:51:29","date_gmt":"2026-05-20T22:51:29","guid":{"rendered":"https:\/\/kohenavocats.com\/jurisprudences\/charles-small-v-the-information-commissioner-anor\/"},"modified":"2026-05-21T00:51:29","modified_gmt":"2026-05-20T22:51:29","slug":"charles-small-v-the-information-commissioner-anor","status":"publish","type":"kji_decision","link":"https:\/\/kohenavocats.com\/ar\/jurisprudences\/charles-small-v-the-information-commissioner-anor\/","title":{"rendered":"Charles Small v The Information Commissioner & Anor"},"content":{"rendered":"
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NCN: [2026] UKFTT 00729 (GRC) Case Reference: FT\/EA\/2025\/0054 First-tier Tribunal (General Regulatory Chamber) Information Rights Heard by Cloud Video Platform Heard on: 23 April 2026 Decision given on: 20 May 2026 Before JUDGE HEALD MEMBER MURPHY MEMBER SCOTT Between CHARLES SMALL Appellant and (1) THE INFORMATION COMMISSIONER (2) THE GREATER LONDON AUTHORITY Respondents Representation: The Appellant appeared in person The 1st Respondent did not attend and was not represented For the 2nd Respondent: Peter Lockley of counsel Decision: 1. The appeal is dismissed. 2. The annex of confidential reasons is provided to the 2nd Respondent only and is not to be sent to the Appellant or the National Archives or published in any other way when the decision is promulgated. REASONS 1. This decision relates to an appeal brought by the Appellant pursuant to section 57 Freedom of Information Act 2000. It is in respect of a decision notice issued by the 1st Respondent on 3 October 2024 (not 4 December 2024 as cited in the appeal form) with reference IC-302022-P3Z9. It concerns part of a request for information made to the 2nd Respondent by the Appellant and the 2nd Respondent's reliance on section 38(2) Freedom of Information Act 2000. 2. What follows is a summary of the submissions, evidence and our view of the law. It does not seek to provide every step of our reasoning. The absence of a reference to any specific submission or evidence does not mean it has not been considered. In this decision any page numbers indicated by their inclusion in brackets refer to pages of the bundle and if the letters CB are added it is to the closed bundle. 3. In this decision the following definitions are used:- Freedom of Information Act 2000 FOIA neither confirm nor deny NCND the public interest balance test the PIBT The Information Commissioner the IC The Greater London Authority the GLA The Appellant's request the Request The IC's decision notice the DN Shonagh Manson of the GLA SKM Upper Tribunal and First-tier Tribunal UT & FtT closed confidential annex of reasons for this decision the Annex statue of John Chilembwe and John Chorley displayed in Trafalgar Square between 2022 and 2024 Antelope NCND 4. The GLA relies on section 38(2) FOIA by which it neither confirms nor denies whether information in-scope of the Request was held. Nothing in this decision is intended to undermine this position and no inferences can be made from this decision about whether or not in-scope information was or was not held at the relevant date. 5. The Appellant had a significant, but inevitable and necessary, disadvantage in this NCND appeal by not being provided with the closed material and at the time of the issue of the appeal not knowing which part of section 38 FOIA it was being said was engaged. The Tribunal sought to ensure that this disadvantage was ameliorated in the closed part of the appeal and by the provision of a gist. Evidence and matters considered 6. For this appeal we had an open bundle of 168 pdf pages. We also had a skeleton provided by counsel for the GLA and a 141 page authorities bundle. 7. We also had closed material held pursuant to rule 14(6) The Tribunal Procedure (First-tier Tribunal) (General Regulatory Chamber) Rules 2009. In dealing with the closed material we kept in mind that we had a continuing duty to ensure fairness with regard to it (Browning -v- Information Commissioner [2014] EWCA civ 1050). The closed material was reviewed by the Tribunal in a closed hearing and an approved gist of that hearing was provided to the Appellant. We held a very short second closed hearing towards the end of the appeal to enable the GLA to respond to one aspect of the Appellant's submissions. No second written gist was produced but the Appellant was given a verbal summary of what had occurred. 8. Included in the open bundle was a witness statement made by the Appellant and a partially redacted statement made by SKM of the GLA who since October 2017 has been the Assistant Director for the Culture, Creative Industries and 24-hour London Unit at the GLA. SKM was involved in dealing with the Request when the GLA responded to it. Both were cross-examined in the open part of the appeal and additionally SKM was asked questions by the Tribunal in the closed hearing. Background 9. The GLA is the devolved governing body for the area of Greater London. Trafalgar Square is an internationally recognised open space in central London. In its centre is "one of the UK\u2019s most famous military monuments, Nelson\u2019s Column, and is named to commemorate his most famous naval victory"(103). 10. Trafalgar Square has a plinth at each of its four corners. Three have permanent statues namely of King George IV, Major General Sir Henry Havelock and General Sir Charles Napier. The 4th plinth (relevant to this appeal) was intended to have a statue of King William IV but this never materialised. Since the late 20th Century there has been a series of commissioned works placed on the 4th plinth. For about two years, between September 2022 and September 2024 this was "Antelope" created by the artist Samson Kambalu who, SKM in her statement says, is: "a Malawi-born artist who at the relevant time was a Professor at Magdalen College, Oxford…" 11. The IC said that Antelope (26) "restages a photograph of Baptist preacher and pan-Africanist John Chilembwe as a sculpture". The GLA explained how the artwork was chosen (37) and what it depicts as follows:- "Between September 2022 and September 2024, the Fourth Plinth featured an artwork called Antelope, by Samson Kambalu, a Malawi-born artist, academic and author. The artwork was chosen by a process that included a public vote on short-listed proposals, in which 17,500 people voted. It restages a 1914 photograph of Baptist preacher and pan-Africanist John Chilembwe and European missionary John Chorley, which is significant as Chilembwe appears wearing a hat in defiance of colonial rule at that time." 12. SKM, in giving evidence, also added that Antelope was not chosen by her or the Mayor of London but was chosen by a commission which included a public vote. 13. The GLA (37) provided information about John Chilembwe saying:- "In 1915, John Chilembwe organised an unsuccessful armed uprising against colonial rule in Nyasaland (now Malawi). He was killed shortly thereafter by colonial forces. He is a controversial figure: on the one hand, he is celebrated as a hero of independence in some African countries, and John Chilembwe Day is observed annually on 15 January in Malawi. On the other, his uprising was violent: William Jervis Livingstone, the owner of a cotton plantation, was killed and beheaded, and shortly afterwards, Chilembwe preached a sermon in a church in which his impaled head was displayed. These matters are documented in publicly available source." 14. In her statement SKM also said (102):- "11…From my own background reading, I understand that Chilembwe led an uprising in 1915 against British colonial rule in what was then Nyasaland, triggered by the mistreatment of refugees from Mozambique and the conscription to fight German troops during the First World War. During the uprising William Jervis Livingstone, the owner of a cotton plantation, was killed and beheaded, and shortly afterwards, Chilembwe preached a sermon in a church in which Livingstone\u2019s impaled head was displayed. Chilembwe was subsequently killed and his church destroyed by the colonial police. Though his rebellion was ultimately unsuccessful, Malawi gained independence in 1964. Malawi celebrates John Chilembwe Day on January 15th and the uprising is viewed as the beginning of the Malawi independence struggle. In the Antelope artwork, Chilembwe is depicted at a larger scale than Chorley. He wears a hat, in defiance of colonial rules of the time which banned Africans from wearing hats." 15. FOIA is almost always "requester blind" and "motive blind" but for background only we also noted that the Appellant, who told us he has a professional interest in political and security risk, in his statement said (167):- "7. My request was made for informational and historical purposes. I did not seek to provoke hostility, target individuals, or inflame public debate. I sought factual correspondence only. There is a large British diaspora of an estimated 2-2.5 million people in Africa, and a large African diaspora in Britain, to whom this issue may be of particular interest. There is also considerable scholarship on the legacies of colonialism, and the requested disclosure would be of particular interest to myself and others from my alma mater, the University of London\u2019s School of Oriental and African Studies. The requested information would be expected to be of interest to those in the public with interest in the British royalty and Christianity due to the plinth initially being dedicated to a King and Supreme Governor of the Church of England." 16. In his reasons for appeal he also said (13):- "I believe that, as a taxpayer of Scottish descent [redacted] who worked for years in [redacted], I have a right to know why my taxes were spent glorifying a terrorist who beheaded a British civilian and gave a sermon next to his impaled severed head. If the GLA have evidence that they have glorified terrorism and incited ethnic hatred, it should not be suppressed based on the idea that there may be some intangible imagined repercussions" 17. At the appeal he said he was just seeking to know if the GLA had any factual correspondence about John Chilembwe for any historical analysis or for any contemporary debates over Christianity and who should be celebrated with a statue. FOIA 18. FOIA provides that any person making a request for information to a public authority is entitled to be informed in writing if that information is held (section 1(1) (a) FOIA) and if that is the case to be provided with that information (section 1 (1) (b) FOIA). These entitlements are subject to a number of exemptions which can be absolute or subject to the PIBT. Section 38 FOIA provides that:- (1)Information is exempt information if its disclosure under this Act would, or would be likely to (a) endanger the physical or mental health of any individual, or (b) endanger the safety of any individual. (2) The duty to confirm or deny does not arise if, or to the extent that, compliance with section 1(1)(a) would, or would be likely to, have either of the effects mentioned in subsection (1). 19. We agree with the GLA's submission in its response based on the decision of the FtT in PETA v ICO & University of Oxford (EA\/2009\/0076) that "endangering" and "prejudicing" amounts to the same thing. 20. The approach to the issue of prejudice is set out in Hogan v The Information Commissioner and Oxford City Council (EA\/2005\/0026 and 0030). This has been appliedin numerous Tribunal decisions and was referred to by the Court of Appeal in Department for Work and Pensions -v- The Information Commissioner and Zola [2016] EWCA 758 at paras 22-27. 21. In Hogan the FtT set out a test (from para 29) by which firstly one must identify the applicable interest within the relevant exemption. Next the nature of the prejudice being claimed must be considered and the "30…evidential burden rests with the decision maker to be able to show that some causal relationship exists between the potential disclosure and the prejudice and that the prejudice is…"real, actual or of substance"and so more than de minimis. Thirdly the likelihood of the occurrence of the prejudice is considered and in this appeal the GLA rely on the lower threshold of "would be likely to.." On this:- (a) in Lownie v Information Commissioner & The National Archives & The Foreign and Commonwealth Office EA\/2017\/0087 the FtT said thatthe words "would be likely "… refers to there being \u2018a very significant and weighty chance\u2019 of occurrence, such that the occurrence \u2018may very well\u2019 occur, a \u2018real risk\u2019 not being enough." (b) in R (Alan Lord) v Secretary of State for the Home Department [2003] EWHC 2073 (Admin) Mumby J held that:- "100 In my judgment "likely" in section 29(1) connotes a degree of probability where there is a very significant and weighty chance of prejudice to the identified public interests. The degree of risk must be such that there "may very well" be prejudice to those interests, even if the risk falls short of being more probable than not." 22. If the exemption is engaged there is then an assessment of the PIBT as to whether the public interest in maintaining the NCND response outweighs the public interest in confirmation or denial. The relevant date for considering the PIBT is the date the public authority makes its decision on a request (or at the end of the time for doing so) (see Montague v ICO and Department for Business and Trade [2022] UKUT 104 (AAC)). At this date Antelope was still on display. 23. In BUAV v Information Commissioner and Newcastle University (EA\/2010\/0064) the FtT (with which we agree) said that:- "53. The public interest in maintaining the s38(1) exemption, where it is engaged, is also strong. Self-evidently, there would need to be very weighty countervailing considerations to outweigh a risk to health or safety…" Role of the Tribunal 24. The Tribunal's role in an appeal by section 57 FOIA is set out in section 58 FOIA which provides that:- (1) If on an appeal under section 57 the Tribunal considers\u2014 (a) that the notice against which the appeal is brought is not in accordance with the law, or (b) to the extent that the notice involved an exercise of discretion by the Commissioner, that he ought to have exercised his discretion differently, the Tribunal shall allow the appeal or substitute such other notice as could have been served by the Commissioner; and in any other case the Tribunal shall dismiss the appeal. (2) On such an appeal, the Tribunal may review any finding of fact on which the notice in question was based. 25. We had regard to authorities such as NHS England -v- Information Commissioner and Dean [2019] UKUT 145 (ACC) and Information Commissioner v Malnick and Advisory Committee On Business Appointments [2018] UKUT 72 (AAC). In Peter Wilson -v- The Information Commissioner [2022] UKFTT 0149 the FtT said (with which we agree):- "30…the Tribunal\u2019s statutory role is to consider whether there is an error of law or inappropriate exercise of discretion in the Decision Notice. The Tribunal may not allow an appeal simply because it disagrees with the Information Commissioner\u2019s Decision. It is also not the Tribunal\u2019s role to conduct a procedural review of the Information Commissioner\u2019s decision making process or to correct the drafting of the Decision Notice.\u201d 26. In Williams v Information Commissioner and Commissioner of Police for the Metropolis [2023] UKFTT 1079 (GRC), the Tribunal said:- 10. In his grounds of appeal, Mr Williams first complains that the Decision Notice is unlawful due to the Commissioner not having examined the information before reaching its decision. We reject this. On receipt of a complaint under s.50(1), the Commissioner is required to determine whether a public authority has dealt with the relevant information request in accordance with the requirements of Part I of FOIA and, if appropriate, issue a Decision Notice. FOIA imposes no procedural requirements as to how this is undertaken. Nor does the Tribunal have any supervisory role. It is for the Commissioner to decide how best to investigate a particular complaint. On appeal, the Tribunal's full merits jurisdiction enables it to consider any further relevant matter. The investigation that was undertaken will also affect the weight afforded by the Tribunal to the Commissioner's conclusion." 27. We also noted Forstater v Information Commissioner and others [2023] UKUT 303 (AAC) where the UT at para 40 said:- "(2) the \u201cordinary presumption\u201d is that it is for an appellant to prove their case. The burden will rest with the appellant except where statute expressly or impliedly provides otherwise:…" (3) however, the concept of the burden of proof is of secondary importance in tribunal proceedings which involve a full merits review, since to apply strict burdens of proof may prevent the tribunal from properly discharging its responsibility to decide the facts for itself and\/or exercise any discretion afresh…" The Request to appeal (summary) 28. On 21 February 2024 the Appellant made the Request in 3 parts including (63):- "Please also provide all correspondence identifying John Chilembwe as responsible for carrying out or directing violent activities, including but not limited to sending his followers to attack missionaries and other civilians, behead Scotsman William Jervis Livingstone and Chilembwe personally giving a sermon next to Livingstone's impaled severed head." 29. The GLA's replied on 20 March 2024 (61). On or about 20 March 2024 the Appellant wrote again and in effect repeated this part of the Request. The GLA took this as a request for an internal review of this element and on 18 April 2024 said (65):- "The GLA can neither confirm nor deny whether it holds the information that you have requested in relation to the final part of your request under the duty in Section 1(1)(a) of the Freedom of Information Act 2000 (the Act) in relation to the following exemptions: \u2022 Section 38(2) Health and Safety." and "Confirming or denying whether or not the GLA does, or does not, hold information relating to this request would potentially instigate a hostile public discourse \u2013 which would be damaging to the GLA, its staff and its property. None of these considerations however should be taken as confirmation that any such information on this subject is or is not held by the GLA." 30. After a further email (68) on 18 April 2024 (misdated 2023) the Appellant contacted the IC to complain (69). He said:- "The GLA are claiming that the risks to personnel and property outweigh the public interest of disclosing whether they hold correspondence relating to the decision to erect a statue of John Chilembwe in Trafalgar Square. Chilembwe famously ordered the murder of a Scottish civilian and preached next to his impaled severed head, so as a Scottish person I'd like to know why my and other taxpayer's money was spent glorifying this man." 31. During the course of the IC's investigation the GLA provided its reasoning which in part is redacted in the open bundle. The IC's conclusion was set out in the DN on 3 October 2024 (1) which in summary was that "2. The Commissioner\u2019s decision is that the GLA is entitled to rely on section 38(2) to refuse to confirm or deny whether it holds any information falling within the scope of this part of the request." Appeal 32. On 15 January 2025 this appeal was commenced. By it the Appellant asked for:- "…full disclosure of all communications relating to the decision to erect a large statue of John Chilembwe in Trafalgar Square, including but not limited to communications that may indicate violations of the Terrorism Act 2006." 33. The grounds of appeal are (13):- " The GLA are refusing to provide information relating to their decision to erect a large statue of a man who within living memory beheaded a Scottish farmer and gave a sermon next to his impaled severed head. This statue was erected in Trafalgar Square, the most important place dedicated to the defence of British people. I have requested information from them about this decision as I feel it is likely to have glorified terrorism and incited ethnic hated, potentially in violation of the Terrorism Act 2006. The GLA have repeatedly refused to hand over information, with the justification being that it is likely to "potentially instigate a hostile public discourse \u2013 which would be damaging to the GLA, its staff and its property." I believe that, as a taxpayer of Scottish descent [redacted] who worked for years in [redacted] I have a right to know why my taxes were spent glorifying a terrorist who beheaded a British civilian and gave a sermon next to his impaled severed head. If the GLA have evidence that they have glorified terrorism and incited ethnic hatred, it should not be suppressed based on the idea that there may be some intangible imagined repercussions." 34. Since the appeal was commenced as well as there being a number of orders made pursuant to rule 14(6) 2009 Rules:- (a) the IC responded on 22 August 2025 (19); (b) the GLA became a party by order of 1 December 2025 (52), responded on 17 December 2025 (32)\/(3CB) and provided a closed annex dated 17 December 2025 (14CB); (c) the GLA filed SKM's statement dated 14 January 2026 (99) and (55CB); and (d) the Appellant provided a statement dated 19 January 2026 (163). Issues 35. The Appellant confirmed that only the part of the Request set out above remained in issue. As the appeal progressed the GLA provided more clarity about its position namely that the endangerment it sought to prevent was the mental health of any person or persons and the NCND response had not been used to prevent harm to GLA staff or property. The issue for the Tribunal to decide is:- (a) would confirmation or denial by the GLA as to whether it holds information within the scope of this remaining part of the Request be likely to endanger the mental health of any person or persons? (b) if yes then, tested at the relevant date, does the public interest in maintaining the exclusion of the duty to confirm or deny outweigh the public interest in disclosing whether or not the GLA holds any in-scope information? Open position of the parties on engagement The DN 36. In the DN the IC said:- "14. Based upon the GLA\u2019s submissions to him the Commissioner is satisfied that if the GLA confirmed whether or not it held information falling within the disputed part of the request this would present a real and significant risk to the issues which the sub-sections of 38(1) are designed to protect. The Commissioner cannot elaborate on his reasoning for this finding without compromising the content of the GLA\u2019s submissions to him." The GLA 37. In its response after internal review the GLA said in general terms and without identifying a specific limb of section 38:- "Confirming or denying whether or not the GLA does, or does not, hold information relating to this request would potentially instigate a hostile public discourse \u2013 which would be damaging to the GLA, its staff and its property…" 38. In its open response (see para 27), in the open skeleton (which was stated to replace the GLA's open response) and at the appeal the GLA's position was put more precisely as follows:- "36. The GLA further submits that the likely increase in vitriolic discourse about Antelope would, in and of itself, have been likely to harm the mental health of one or more individuals in March 2024." thus identifying part of section 38(1)(a) FOIA as the endangerment the NCND response sought to prevent. 39. At the appeal, counsel for the GLA gave a more precise explanation saying that the NCND response had not been used to protect harm to GLA staff seeing the hostile discourse but it arose from a "one off situation" and a specific set of circumstances relating to one of more individuals. 40. In SKM's statement she said for example (110):- "35. To be clear, this is not a case of the GLA shying away from addressing these issues. There is room for debate, and disagreement about which historical figures merit public commemoration and celebration. There is no singular answer to the question of how history should judge those who used extreme or illegal methods to achieve change. Art plays a strong role in creating such spaces for debate and for changing discourse. Unfortunately, however, the debate is not always conducted in reasonable terms. I have described above how the Fourth Plinth is a focus for a particularly vitriolic strain of public discourse, including open threats to individuals including the Mayor, and with the threat of criminal damage being carried out to the art works displayed on it. Even then, the GLA does not duck these issues, and remains committed to commissioning thought-provoking artwork for the Fourth Plinth." 41. The GLA's concerns were evidenced in the open bundle by extracts from news articles and screen shots of posts from X. Examples from the period up to the date of response include press reports of statues being targeted for protests in central London in June 2020 and comments on the Mayor of London's X account after he announced that Antelope would be on the 4th plinth. Such comments include complaints about the choice and subject of the artwork itself and of the Mayor of London. These are not repeated here save that for example we noted the following said about Antelope "Hopefully some [redacted]will tear it down or deface it…" "Should be Colston'd" 42. The GLA's open reasons for its conclusion can be summarised as follows:- (a) the commissioning, subject matter and location of Antelope was considered controversial and resulted in polarised and at times hostile discourse; (b) Trafalgar Square has been a location for demonstrations and there has been a number of attacks on statues. The subject matter of Antelope was considered, by some, to be inappropriate for its location in Trafalgar Square; (c) the Tribunal will not be able to decide if the posts on X in the bundle are "real" but even fake posts can induce real world actions; (d) some on-line debate had as its focus the Mayor of London who is a "hate figure" for some people and is the subject of distressing on-line abuse some of which is racist; (e) the issue of statues has become politically charged recently and can be a lighting rod for cultural disputes; (f) a section of the public when expressing disagreement about Antelope do so aggressively using "profane language, drawing a highly offensive comparison to the Nazis, and threatening or inciting criminal damage to the artwork"; (g) this statue "…had the potential to act as a flashpoint for a wider sense of grievance, including for those who had never previously heard of John Chilembwe or of the artist"; (h) "the reaction to the artwork is bound up with a wider discourse about the value of public art that raises questions as to nationalism, colonialism, and militarism, about whether society should continue to honour historic figures connected with slavery or colonialism, and more broadly still about immigration and national identity" ; (i) the publicly visible Request itself is expressed in graphic and "inflammatory language" and even though the Appellant may say the words he used are merely factual this plays into the concerns of people who may feel outraged that the GLA would support such an artwork some of whom engage in the type of "vitriolic discourse" seen in the evidence; (j) if the GLA responds to the Request by saying it has some in-scope information it will be attacked for allowing this statue to occupy the 4th plinth with that knowledge and if it says it does not then it will be criticized for going ahead with the commission without such knowledge; (k) if the GLA responded in any other way than with a NCND response this would be "likely to instigate, reignite, or exacerbate a hostile public discourse." and there is a "realistic possibility that the reaction could tip over into physical damage to the artwork…" 43. These concerns, with those also set out in the closed evidence, were the basis of the GLA's conclusion that:- " 37….at the material time there was, overall, a real and significant risk that confirming or denying whether the GLA holds information within scope of…the Request would be likely to harm the mental health of one or more individuals…" The Appellant 44. The Appellant in his appeal (164) said for example that he did not consider disclosure to present a real or significant risk of unrest. He said he was not aware of any organized movement, campaign or protest activity connected to the historical events and said he was not aware of any violence, threats, protests or police involvement regarding Antelope. He said that he was not "…aware of any individual whose mental health was demonstrably harmed as a result of the matters referred to in my request." 45. At the appeal itself the Appellant told us that the public were aware of the historical context at the time and as far as he knew that had not led to any threats or damage to Antelope. He did not believe that Antelope had been a target for "statue toppling". 46. He also said that he had looked at the open evidence about this subject. He said that there exists within most military cyber activity including the use of bots and people posting comments on social media for their own national policy objectives. This can be "nasty" and may appear as hostile discourse but, in his view, comments on social media cannot be attributed easily and without investigation. In addition this sort of material may not result in any real-world activity or risk. 47. In closing the Appellant also made submissions about the artist from what he had read, about hostile public discourse and social media intelligence, the inability to prove cause and effect from X posts and the importance of the 4th plinth to some who had wanted a statue of the late Queen Elizabeth 11 to be placed there. Evidence from cross-examination 48. SKM was asked how one would know if hostile social media activity could be shown to be "genuine" and have real world harmful causal effects. SKM agreed the GLA could not know but operated (responsibly in its view to manage risk) on the basis that it may have harmful outcomes. It was also suggested that if the GLA is permitted to respond as it has then anyone could simply by writing angry tweets, shut down debate on any issue which would not support democratic activity. SKM repeated the GLA's arguments for its NCND response as far as she could which was summarised as being that if the GLA either confined or denied it had any material in-scope of the Request the outcome could lead to "hostile discourse leading to the risk of mental health harm in one or more individuals and the potential of real world impacts.." 49. The Appellant also asked to understand why the GLA could not have released something or make a proportionate response. SKM said that she understood why, in the absence of the closed material, it was hard for the Appellant to understand but that their case was presented in the closed material. 50. It was suggested to SKM that the GLA in 2022 would have been aware from other protests that statues can provoke criminal damage, hostile public discourse and protests and that the GLA's intention appears to have been to create discourse about a man "who carried out violent activity against British civilians." SKM said that the intent was "to open a space for debate" and the GLA was not seeking to "duck the issues" but that does not make hostile debate acceptable especially where exacerbated by the closed evidence. She also said that any hostile discourse was the result of a long running historical issues and not because of one statue. 51. The Appellant was asked more about the use of bot accounts on social media and how it can be investigated. He said he could not say if the posts on X seen in the bundle were or were not authentic because there is such a widespread use of bots now using AI generated content. He could not say if "locals" were even seeing them because bots were sharing posts between themselves to generate the appearance of engagement. He said the GLA could not know if they were authentic or not without investigation. He also said it was often unclear if this sort of cyber warfare had any real world impact. 52. He was also asked about the content of the Request itself. He agreed his interest was in political and social unrest and that the Request was in graphic terms because the relevant activity, about which he is concerned, was itself violent and graphic. He did not accept he was opposed to Antelope and said that he was interested in how the attitudes of governments and perspectives to events can change over time. It was suggested to him that if the GLA did not use a NCND response then, whatever his motives, the terms of the Request whatever the GLA's reply would feed the sense of outrage seen in the posts on X. The Appellant called this "accountability". Other than this he could not say if the Request, if answered, would trigger public outrage. Position of the parties on the PIBT The GLA 53. The GLA said after its internal review (66):- "The GLA acknowledges there is a legitimate interest in the GLA being transparent and accountable…There is a strong public interest in not making any public statement that confirms or denies the existence of information that would be likely to prejudice health and safety of any individual. In this case, the public interest in maintaining the exclusion of the duty to confirm or deny outweighs the public interest in confirming or denying whether we hold the information in question. These considerations should not be taken as conclusive evidence that the information you have requested is or is not held by the GLA" 54. SKM's evidence on the PIBT was that (111) she concluded:- (a) the public interest in the GLA confirming or denying if it had information was "fairly low"; (b) there was already information in the public domain about the subject of Antelope and there was already a debate about how he should be commemorated; (c) confirming or denying would add little to this debate and any criticism of the decision to commission Antelope did not require the GLA to respond; and (d) "…there was clearly a significant public interest in avoiding a deterioration in the mental health of one or more people". 55. In summary the GLA accepted that there was public interest in transparency and that confirming or denying whether it holds information within the scope of the Request would support this. However the GLA said that this public interest is reduced in this case because:- (a) considerable information about the commissioning of Antelope was already in the public domain; (b) responding would add very little understanding or add to the quality of any debate or academic knowledge; (c) it was not an especially controversial decision that "cries out for explanation, or the fullest possible disclosure to enable the public to understand it…"; and (d) the 4th plinth is not a "sacred site " for Christians or Royalty and the original intention to use it for a statue of William IV is of historic interest only. 56. In the GLA's view this is not a case where disclosure is necessary to satisfy the public interest despite the risk of harm identified and the public interest balance is in preventing the harm identified. Its position was accepted by the IC in the DN. The Appellant 57. The Appellant in an email to the GLA said (68):- "It is clearly in the British public's interest to know the process behind using taxpayer's money to glorify a man who preached next to the impaled severed head of a British person, and I do not agree with your assessment of the imagined consequences of releasing all correspondence relating to this GLA decision. 58. In his complaint he said:- "The GLA are claiming that the risks to personnel and property outweigh the public interest of disclosing whether they hold correspondence relating to the decision to erect a statue of John Chilembwe in Trafalgar Square. Chilembwe famously ordered the murder of a Scottish civilian and preached next to his impaled severed head, so as a Scottish person I'd like to know why my and other taxpayer's money was spent glorifying this man." 59. In the appeal and his statement the issue was not addressed in material terms but we did note in his statement he said (164):- "7…There is a large British diaspora of an estimated 2-2.5 million people in Africa, and a large African diaspora in Britain, to whom this issue may be of particular interest. There is also considerable scholarship on the legacies of colonialism, and the requested disclosure would be of particular interest to myself and others from my alma mater, the University of London\u2019s School of Oriental and African Studies. The requested information would be expected to be of interest to those in the public with interest in the British royalty and Christianity due to the plinth initially being dedicated to a King and Supreme Governor of the Church of England." 60. He was asked at the appeal for his submissions on the PIBT in the event that the Tribunal decided that harm would be likely to result from the GLA having to say if they held relevant material or not. He said he was on the side of "harm avoidance" but it was an historical issue where the facts had already been acknowledged but the internal decision making of the GLA was not in the public domain. He said there would be interest from an academic institution in London and those engaged in African studies. He said it would be of interest to people in Africa and the African diaspora in the UK. He also thought the approach of the GLA would be interesting to scholars of governance as a case study of how attitudes towards events and people changes. He noted the 4th plinth's original purpose being to hold a statue of a King and head of the Church of England. He added that it would be against the public interest if there was to be a precedent set that something that creates a hostile public discourse which might lead to someone being harmed mentally meant that there would be less public authority transparency and accountability. Tribunal's review 61. While much of the appeal was focused on the evidence about hostility towards and about Antelope it is worth recording for balance that SKM in her evidence said that:- "10…Antelope was one of six artworks shortlisted in 2021 to be installed on the Fourth Plinth in 2022. It was shown (in \u2018maquette\u2019 or miniature form) at the National Gallery alongside the other shortlisted works. Over 130,000 people visited the exhibition. The public were invited to comment on the works and almost 17,500 voted for their favourite during the course of the exhibition, with Antelope receiving the most votes by a significant margin. The Fourth Plinth Commission Group then selected Antelope to be installed on the Fourth Plinth, taking into account its own considerations and the public comments from the exhibition.." Engagement 62. From what was presented to us in open and the closed part of the appeal we concluded that confirmation or denial by the GLA of whether it held material within the scope of the remaining relevant part of the Request would be likely to endanger the mental health of any person or persons and that this harm would be real, actual and of substance. In reaching this decision we concluded and decided that:- (a) statues have at times been subject to attack and can become a focal point for demonstrations and dispute; (b) Antelope was inevitably going to be considered by some to be a controversial choice for the 4th plinth in Trafalgar Square however many votes it got; (c) its choice did result in polarised views (whether real or bot generated); (d) the controversy arose because some felt there was a better use of the 4th plinth and also because its commissioning was perceived to be connected to the Mayor of London who is a regular recipient of on-line hostility; (e) some reaction was only obliquely linked to the artwork itself as it was often used as a forum to criticize the Mayor of London for example about ULEZ and knife crime; (f) the subject matter of Antelope was always likely to cause a polarised reaction as it draws attention to a colonial era and highlights a person and an event which is capable of wide ranging reactions even where many of the facts are agreed; (g) whether or not it could be demonstrated that it was the choice of Antelope that caused there to be the risk of hostile discourse and activity is not a relevant consideration in this appeal because we are not carrying out a judicial review of the GLA or seeking to decide liability; (h) some of the reaction shown to us in evidence is at times very hostile including that at least one hoped the artwork would be torn down or defaced; and (i) in the absence of detailed forensic evidence it would be very hard to know if a particular post is genuine and whether or not it has had any real world impacts or caused any actual reaction but some or all may be genuine and it was reasonable for the GLA, in responding to the Request, to proceed on that basis. 63. We agreed with the GLA's position that if it answered the Request the public nature of the FOIA process would mean that hostile reactions and attacks might start up again at a time Antelope was still in place. As this was not how the GLA did respond we cannot know with certainty what would then have occurred. However, based on their experience with the need to protect the statues of Churchill and Mandela we agree that is was right for the GLA to be concerned about a possible direct attack on the statue itself as well as the re-emergence of the hostile social media activity. 64. There were submissions made about the content of the publicly available Request and how this risked playing into the concerns of people who may feel outraged about Antelope and that "Confirmation or denial was therefore likely to trigger further hostile discourse, particularly online." The GLA in its submissions made it clear that it did not assert that the Appellant would behave in such a way and recognised that he would say that "he did not seek to provoke hostility or inflame public debate" and that the words used in the Request are merely factual. However:- (a) in this appeal the Appellant's motives, while explained to us a number of times, were not a relevant consideration when determining the issues; (b) we did not conclude, on the evidence presented, that the words used and its publication had caused there to be an increase in hostile discourse or other activity; (c) hostile online discourse existed prior to the Request being made; and (d) the words of concern played no material part in our conclusion that section 38(2) was engaged. 65. Had this been the only part of the GLA's case we think it probable we would not have found section 38 FOIA to be engaged because seeking to prevent hostile discourse or X posts attacking the Mayor of London or even damage to a statue are not in themselves endangerments that section 38 FOIA seeks to prevent. 66. However we concluded that section 38 FOIA was engaged. This was as a result of what we have concluded above and what would be likely to result from the above as set out in the closed material and closed evidence, that we accepted. 67. It is also important for us to record that our decision, that section 38 is engaged, is fact specific, based upon very particular circumstances and does not create a precedent of the type about which the Appellant expressed concern. The PIBT 68. We considered this as at the date of the GLA's response but we also concluded that the position would be the same had we considered it at the date of the response after internal view which contained the GLA's reliance on section 38(2) FOIA. 69. Reasons why the public interest would favour the GLA having to disclose whether or not it held in-scope material at the relevant date include:- (a) because it is in the public interest for public authorities to be transparent in their decision making processes because this enables there to be greater accountability about what a public authority is doing and how it is spending public funds; (b) because it would enable the public to have greater understanding about the role of a public authority; (c) because it is in the public interest for there to be greater awareness of what (if anything) a public authority takes into account when such decisions are being taken; (d) because it is in the public interest for there to be greater understanding about the way in which attitudes towards people and events can change overtime; and (e) more specifically in this case because:- (i) Antelope was placed in a very high profile public and famous location and was intended to, or at least bound to, attract widespread interest and attention and (ii) because the commissioning of Antelope was intended, as SKM said, to create the space for appropriate debate and the GLA's response to the Request may have added to that debate. 70. We also concluded that the public interest in the GLA responding in this case was reduced by the amount of material already in the public domain about the people represented in the artwork, their history and how Antelope came to be commissioned. 71. Notwithstanding the above in our view the public interest is against requiring the GLA to say whether or not it held material in scope of the Request. This conclusion was reached because:- (a) we did not conclude that there were "very weighty countervailing considerations" (BUAV); (b) of the evidence we saw and accepted in the closed material as set out in the Annex; and (c) in our view the public interest in the prevention of the endangerment identified in closed material was on balance greater than the public interest in disclosure. Decision 72. In our view therefore:- (a) if the GLA had confirmed or denied that it held information within the scope of the remaining part of the Request there would have been a very significant and weighty chance thatthe mental health of any person or persons would have been endangered and this harm would have been real, actual and of substance; and (b) tested at the relevant date the public interest in maintaining the exclusion of the duty to confirm or deny outweighed the public interest in disclosing whether or not the GLA held any in-scope information. 73. Accordingly, for the reasons set out above and in the Annex, the DN is in accordance with the law and to the extent that it involved an exercise of discretion the IC exercised it correctly. 74. The appeal is therefore dismissed. SignedJudge Heald Date:15 May 2026<\/p>\n<\/div>\n

\n

Sources officielles :<\/strong> consulter la page source<\/a><\/p>\n

Open Justice Licence v2.0 (The National Archives). Republication avec attribution. Computational analysis necessite accord complementaire.<\/em><\/p>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

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